Office for Nuclear Regulation

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Hunterston A site inspection

Executive summary

Purpose of intervention

This report covers interventions in pursuit of the ONR integrated intervention strategy for Hunterston A, in particular to address regulatory issues identified as part of Inspection plan and carry out the planned Compliance inspections

Interventions Carried Out by ONR

This report covers interventions at Hunterston A mainly to address Compliance inspection and follow-up of regulatory actions placed on the site from previous inspections as follows:-

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A.

Key Findings, Inspector's Opinions and Reasons for Judgements Made

Only the Compliance inspections and follow–up inspections are included in the executive summary as all other interventions are for information only.

LC 11 (Emergency Arrangements)- The purpose of the intervention was for the site to demonstrate to ONR the adequacy of their emergency arrangements and capability, in line with the LC 11 requirements, through an emergency exercise (Level 1 exercise).  ONR and the Magnox Ltd (MxL) internal assurance function found a number of areas for improvement as well as areas of good practice during the exercise.  In conclusion, for Site Licence Condition 11, “Emergency Arrangements” I consider an IIS Rating of 3 (adequate) to be appropriate.  However, there are a number of areas for improvement and these will be communicated to the site following the regulator receipt of the MxL internal assurance report for the exercise and consideration of the content of that report.

LC12 (Duly authorised and other suitably qualified and experienced persons) - The purpose of the intervention was to undertake an inspection of the licensee’s arrangements and implementation under LC 12.  The focus of the inspection was to consider two areas, the SQEP process for the “Process DAP” role, which is a site specific DAP role introduced in June 2014. The position was introduced to provide DAP cover for the waste processing facilities and the SQEP process for the Appointed SQEP roles for maintenance under LC 28, 6(d).  With regard to the Process DAP role, ONR found a number of areas for improvement within the detailed SQEP arrangements and implementation for that particular role.  With regard the appointed SQEP for Maintenance, ONR found that the licensee’s due process had not been followed.  In conclusion, for Site Licence Condition 12, , I consider an IIS Rating of 4 (below standard) to be appropriate because the licensee has not followed their own arrangements with regard to the appointment of SQEP.  I have required the site to address the shortfalls with the implementation of the arrangements.  A level 4 issue will be raised on the ONR issues database and a letter sent to site to address the issue.  This issue is raised on the licensee to address the position with regards to the appointment of SQEP individuals to undertake control and supervision of operations.  There will be a follow up inspection in December 2015 under LC 12 to confirm that this has been addressed.  

LC 26 (Control and supervision of operations) - The purpose of the intervention was to undertake an inspection of the licensee’s arrangements and implementation under LC 26.  The focus of this intervention was to observe the “Process DAP” carrying out his duties in his role as the duly authorised person.  A number of operations under the control and supervision of the Process DAP were observed.  The individual delivered good quality control and supervision.  In conclusion, for Site Licence Condition 26, I consider an IIS Rating of 3 (adequate) to be appropriate. An area for improvement however was identified. This is related to ensuring that the DAP role and the execution of DAP control and supervision is in line with the significant operational activities called upon in the site arrangements which need to be referred to in the facility operating instructions. 

Conclusion of Intervention

The inspection raised issues regarding the implementation of the arrangements under LC 12 with regard to appointed SQEP and thus a letter will be sent to the site and an issue placed on ONR’s regulatory issues database for follow-up.  I will monitor this issue and through a further inspection of LC 12, planned at an appropriate time, to assess the adequacy of the licensee’s full implementation of the arrangements.